CSV Renraj (HUF) Vs ITO (ITAT Bangalore)
In CSV Renraj (HUF) Vs ITO, the ITAT Bangalore allowed the appeal of the assessee and deleted an addition of Rs.9,40,000 made under Section 69A of the Income-tax Act, 1961 in relation to cash deposits during the demonetisation period.
The appeal was filed against the order dated 30.11.2025 passed by the Commissioner of Income Tax (Appeals), NFAC, for Assessment Year 2017-18, which had confirmed the addition under Section 69A. The assessee also filed a petition seeking condonation of delay of 28 days in filing the appeal before the Tribunal. The assessee explained that the delay occurred because the appellate order had been communicated electronically through the Income Tax portal and was not immediately noticed. The assessee stated that there was a bona fide belief that such orders would also be physically served, as was the earlier practice. It was submitted that the delay was neither intentional nor deliberate but occurred due to a genuine misunderstanding regarding electronic communication.
The Departmental Representative did not raise any serious objection to condonation considering the length of delay. The Tribunal observed that the delay of 28 days was neither inordinate nor attributable to negligence or mala fide intention. Holding that the explanation furnished was reasonable and supported by bona fide circumstances, the Tribunal adopted a justice-oriented approach and condoned the delay, admitting the appeal for adjudication on merits.
